STUDY OF EARNINGS STRIPPING PROVISIONS.

SEC. 424. STUDY OF EARNINGS STRIPPING PROVISIONS.(a) In General.—The Secretary of the Treasury or the Secretary’s delegate shall conduct a study of the effectiveness of the provisions of the Internal Revenue Code of 1986 applicable to earnings stripping, including a study of—(1) the effectiveness of section 163(j) of such Code in preventing the shifting of income outside the United States,(2) whether any deficiencies of such provisions place United States-based businesses at a competitive disadvantage relative to foreign-based businesses,(3) the impact of earnings stripping activities on the United States tax base,(4) whether laws of foreign countries facilitate stripping of earnings out of the United States, and(5) whether changes to the earning stripping rules would affect jobs in the United States.118 STAT. 1520(b) Report.—Not later than June 30, 2005, the Secretary shall submit to the Congress a report of the study conducted under this section, including specific recommendations as to how to improve the provisions of such Code applicable to earnings stripping.